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EXHIBIT D
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GIUFFRE

vs.
MAXWELL
Deposition

VIRGINIA GIUFFRE

05/03/2016

Agren Blando Court Reporting & Video, Inc.

216 16th Street, Suite 600
Denver Colorado, 80202
303-296-0017
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IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

Civil Action No. 15-cv-07433-RWS

CONFIDENTIAL VIDEOTAPED DEPOSITION OF

VIRGINIA GIUFFRE May 3, 2016

VIRGINIA L. GIUFFRE,

Plaintiff,

v.

GHISLAINE MAXWELL,

Defendant.

APPEARANCES:

FAMER, JAFFE, WEISSING, EDWARDS, FISTOS &

LEHRMAN, P.L.
By Brad Edwards, Esq.
425 N. Andrews Avenue
Suite 2
Fort Lauderdale, FL 33301
Phone: 954.524.2820
brad@pathtojustice.com
Appearing on behalf of the
Plaintiff

BOIES, SCHILLER & FLEXNER LLP

By Sigrid S. Mccawley, Esq. (For Portion)
401 East Las Olas Boulevard
Suite 1200
Fort Lauderdale, FL 33301-2211
Phone: 954.356.0011
smccawley@bsfllp.com
Appearing on behalf of the
Plaintiff

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1 APPEARANCES: (Continued)

2 HADDON, MORGAN AND FORMAN, P.C.

By Laura A. Menninger, Esq.
3 Jeffrey S. Pagliuca, Esq.
150 East 10th Avenue
4 Denver, CO 80203
Phone: 303.831.7364
5 lmenninger@hmflaw.com
jpagliuca@hmflaw.com
6 Appearing on behalf of the
Defendant
7
Also Present:
8 Brenda Rodriguez, Paralegal
Nicholas F. Borgia, CLVS Videographer
9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

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1 Pursuant to Notice and the Federal Rules

2 of Civil Procedure, the VIDEOTAPED DEPOSITION OF

3 VIRGINIA GIUFFRE, called by Defendant, was taken on

4 Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150

5 East 10th Avenue, Denver, Colorado, before Kelly A.

6 Mackereth, Certified Shorthand Reporter, Registered

7 Professional Reporter, Certified Realtime Reporter

8 and Notary Public within Colorado.

9
* * * * * * *
10 I N D E X
11
EXAMINATION PAGE
12
MS. MENNINGER 8
13

14 PRODUCTION REQUEST(S):

15 (None. )
16

17

18

19

20

21

22

23

24

25

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1 wanted to know about the Prince Andrew incident.

2 Q So that's a different piece of paper?

3 A Yeah, that's just random paper.

4 Q So you had a green spiral notebook that

5 you began sometime in 2011 or 2012 in which you wrote

6 down your recollections about what had happened to

7 you, and you burned that in a bonfire in 2013.

8 Did I get that right?

9 A You got that right.

10 Q And do you have no other names of people

11 to whom you claim Ghislaine Maxwell directed you to

12 have sex, correct?

13 A At this time, no.

14 Q Is there any document that would refresh

15 your recollection that you could look at?

16 A If you have a document you'd like to show

17 me, I would be glad to look at it and tell you the

18 names I recognize off of that.

19 Q I'm just asking you if there's a document

20 you know of that has this list of names in it?

21 A Not in front of me, no.

22 Q Where is the original of the photograph

23 that has been widely circulated in the press of you

24 with Prince Andrew?

25 A I probably still have it. It's not in my

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1 possession right now.

2 Q Where is it?

3 A Probably in some storage boxes.

4 Q Where?

5 A In Sydney.

6 Q Where in Sydney?

7 A At some family's house. We got the boxes

8 shipped to Australia, and they were picked up off the

9 porch by my nephews and brought to their house.

10 Q Which is where?
11 A In Sydney.
12 Q Where in Sydney?

13 A Bass Hill.
14 Q And who lives in that house?
15 A Well, it's owned by my mother-in-law and

16 father-in-law, but my nephews live in the house.

17 Q What are their names?

18 A I'm not giving you the names of my

19 nephews.

20 Q What's the address of the house?

21 A Why would you want that?

22 Q I want to know where the photograph is.

23 I'm asking you where the photograph is. And you've

24 just told me it's somewhere in Bass Hill?

25 A Yes.

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1 Q So where in Bass Hill is the photograph

2 located?

3 A If I can't 100 percent say that the

4 photograph is there, it could be at my house that I

5 presently live in. I'm not going to give you the

6 address of my nephews' residence.

7 Q When is the last time you saw the

8 photograph in person?

9 A When I packed and left America.

10 Q Colorado?
11 A Yes.
12 Q All right. So you had that photograph

13 here with you in Colorado?

14 A Yes.
15 Q What's on the back of the photograph?
16 A I'm sorry?

17 Q Is there anything on the back of the

18 photograph?

19 A There's like the date it was printed, but

20 no writing or anything.

21 Q Okay. Does it say where it was printed?

22 A I don't believe so. I think it just I

23 don't remember. I just remember there's a date on

24 it.

25 Q Whose camera was it taken with?

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1 A My little yellow Kodak camera.

2 Q Who took the picture?
3 A Jeffrey Epstein.
4 Q And where did you have it developed?

5 A I believe when I got back to America.

6 Q So where?
7 A I don't know.
8 Q Palm Beach?

9 A I don't know.
10 Q What is the date the photograph was

11 printed?
12 A I believe it's in March 2001.
13 Q Okay.
14 A But that's just off of my photographic

15 memory. I don't -- it could be different, but I

16 think it's March 2001.

17 Q You have a photographic memory?

18 A I'm not saying I have a photographic

19 memory. But if I'd look at the back of the photo and

20 I remember what it says, I believe it was March 2001.

21 Q Did the photograph ever leave your

22 possession for a while?

23 A I gave it to the FBI.
24 Q Okay. And when did you get it back?
25 A When they took copies of it.

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1 Q When was that?

2 A 2011.

3 Q When they came to interview you?

4 A Yes.

5 Q So from 2011 until you left Colorado it

6 was in your personal possession?

7 A Yes.

8 Q What other documents related to this case

9 are in that, storage boxes in Australia?

10 MR. EDWARDS: Object to the form.
11 A Documents related to this case -- there
12 I don't know. I really can't tell you. I mean,

13 there's seven boxes full of Nerf guns, my kids' toys,

14 photos. I don't know what other documents would be

15 in there.

16 Q (BY MS. MENNINGER) Did anyone search

17 those documents after you received discovery requests

18 from us in this case?

19 A I haven't been able to obtain those boxes.

20 I can't get them sent back up to me. It's going to

21 cost me a large amount of money. And right now I'm

22 trying to look after my family, so I'm not able to

23 afford to get them up.

24 Q You live in Australia, correct?

25 A I do.

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1 Q Okay. How far away are the boxes from

2 where you live in Australia?

3 A Sydney is down here at the bottom. Cairns

4 is up here at the top.

5 Q Okay.

6 A It's probably a six-day drive.

7 Q Did you fly here through Sydney?

8 A No.

9 Q Have you been to Sydney since you've moved

10 back to Australia?

11 A I flew into Sydney with my three kids, but

12 it was a connecting flight to Brisbane.

13 Q Did you ask your nephews or anyone else to

14 search those boxes in response to discovery requests

15 that we issued in this case?

16 A They are my nephews. I would never let

17 them look at those.

18 Q Other than your green spiral notebook,

19 what else did you burn in this bonfire in 2013?

20 A That was it.

21 Q That's the only thing?

22 A Yes.
23 Q Did you use wood?
24 A Yes.

25 Q Charcoal?

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1 A My husband built the bonfire out of wood

2 and I don't know what else he put in it. He's the

3 one who always makes the fires, not me.

4 Q Who else was present?

5 A Just him and I.

6 Q Were your kids there?

7 A No. They were inside sleeping.

8 Q And what beach was this?

9 A It wasn't a beach. It was in my backyard.

10 Q What's your address?
11 A At that time?
12 Q Um-hum.
13 A Jane Doe 2
14 Q Jane Doe 2
15 A Yes.
16 Q Who were your neighbors?
17 A Sweet people. Ray and -- I could look on

18 my phone if you want.

19 Q No, thank you. Do they still live there?

20 A Yes.
21 Q Do you keep in touch with them?
22 A Last time I talked to them was a few

23 months ago.
24 Q Did they see the fire?

25 A They've seen many fires that we've had.

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1 We've had lots of bonfires there.

2 Q Did you ever ride in a helicopter with

3 Ghislaine Maxwell acting as pilot of the helicopter?

4 A Yes.
5 Q Who else was on the flight?

6 A I've been on the helicopter with her

7 plenty of times. I can't mention how many people

8 were on the -- on the helicopter at the same time.

9 Q How many times?
10 A I don't know. Do you have helicopter

11 records that you could show me?

12 Q I'm asking you how many times you were on

13 the helicopter with Ghislaine Maxwell acting as the

14 pilot --
15 A It's impossible for me to answer the

16 question without having the actual physical records

17 in front of me.
18 Q I'm asking you to look into your memory

19 and tell me how many times you recall being on a

20 helicopter with Ghislaine Maxwell at the pilot seat?

21 A There is no number I can give you.

22 There's plenty of times I've been on her helicopter.

23 Q Where did you go from and to on a

24 helicopter?
25 A I believe it was -- don't quote me on this

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1 because I get confused on the islands there. I want

2 to say it was St. John's. It could have been

3 St. Barts. St. John or St. Barts, and then we would

4 fly straight to Jeffrey's island.

5 Q Okay. Did you ever go anywhere else on

6 the helicopter?
7 A No.
8 Q Were you ever on the helicopter with Bill

9 Clinton and Ghislaine Maxwell as the pilot of the

10 helicopter?
11 A No.
12 Q Were you ever on the helicopter with Bill

13 Clinton's Secret Service and Ghislaine Maxwell as the

14 pilot?
15 A No.
16 Q Do you recall telling Sharon Churcher that
17 you were?
18 A No.
19 Q Did you see the press article in which

20 Sharon Churcher reported that you were?

21 MR. EDWARDS: Objection. I'd just ask

22 that if you're going to ask this witness about a

23 specific article I'd like for her to see the article.

24 Otherwise she's not going to testify about it.

25 If you have something to show her, then,

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1 please.
2 Q (BY MS. MENNINGER) Do you recall seeing a

3 press article in which Sharon Churcher reported that

4 you were on a helicopter with Bill Clinton and

5 Ghislaine Maxwell as the pilot?

6 MR. EDWARDS: Again, I'll let you answer

7 the question once she's looking at the document that

8 you're being asked about.

9 MS. MENNINGER: You're not letting her

10 answer a question about whether she recalls a

11 particular press statement?

12 MR. EDWARDS: I will let her answer every

13 question about the press statement as long as she

14 sees the press statement. I'm okay with that. She

15 can answer all of them.

16 MS. MENNINGER: No, there is a rule of

17 civil procedure that allows you to direct a witness

18 not to answer a question when there's a claim of

19 privilege.

20 What privilege are you claiming to direct

21 her not to answer this question?

22 MR. EDWARDS: I thought that you wanted

23 accurate answers from this witness. If the

24 MS. MENNINGER: I asked her if she

25 recalled something --

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1 MR. EDWARDS: If the sole purpose is to

2 just to harass her --

3 MS. MENNINGER: I asked her if she

4 recalled something --

5 MR. EDWARDS: Then that's just not going

6 to be what's happening today.

7 Q (BY MS. MENNINGER) All right. So you're

8 refusing to answer a question about whether you

9 recall a particular press statement

10 MR. EDWARDS: She's --
11 Q (BY MS. MENNINGER) -- is that true?
12 MR. EDWARDS: She is not refusing to

13 answer any questions. She --

14 A I'm not refusing to answer. I just want

15 to see the article you're talking about so I can be

16 clear in my statement.
17 Q (BY MS. MENNINGER) Do you recall seeing a

18 press article written by Sharon Churcher reporting

19 that you flew on a helicopter with Bill Clinton and

20 Ghislaine Maxwell as the pilot?

21 A No, I do not recall reading a press

22 article saying that I was on a helicopter with Bill

23 Clinton as Ghislaine is the pilot.

24 Q Do you recall telling Sharon Churcher that

25 you had conversations with Bill Clinton regarding him

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1 flying on a helicopter with Ghislaine Maxwell?

2 A I believe that it was taken out of

3 context. Ghislaine told me that she flew Bill

4 Clinton in. And Ghislaine likes to talk a lot of

5 stuff that sounds fantastical. And whether it's true

6 or not, that is what I do recall telling Sharon

7 Churcher.
8 Q So you told Sharon Churcher that Ghislaine

9 Maxwell is the one who told you that she flew Bill

10 Clinton in the helicopter?

11 A I told Sharon Churcher that Ghislaine flew

12 Bill Clinton onto the island, based upon what

13 Ghislaine had told me.

14 Q Not based upon what Bill Clinton had told

15 you, correct?
16 A Correct.
17 Q Did you ever ask Sharon Churcher to

18 correct anything that was printed under her name,

19 concerning your stories to Sharon Churcher?

20 A I wasn't given those stories to read

21 before they were printed.

22 Q After they were printed did you read them?
23 A I tried to stay away from them. They were

24 very hard. You have to understand it was a very hard

25 time for me and my husband to have to have this

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1 public -- we didn't think it was going to be this

2 publicly announced and that big. So we turned off

3 the news and we stopped reading so many things.

4 Q You didn't read the articles about your

5 stories to Sharon Churcher

6 A I've read some articles

7 Q Let me just finish. You did not read the

8 articles published by Sharon Churcher about your

9 stories to Sharon Churcher?

10 A I have read some articles about what

11 Sharon Churcher wrote. And a lot of the stuff that

12 she writes she takes things from my own mouth and

13 changes them into her own words as journalists do.

14 And I never came back to her and told her

15 to correct anything. What was done was done. There

16 was nothing else I can do.

17 Q So even if she printed something that were

18 untrue you didn't ask her to correct it, correct?

19 A There was things that she printed that

20 really pissed me off, but there was nothing I could

21 do about it. It's already out there.
22 Q She printed things that were untrue,

23 correct?
24 MR. EDWARDS: Objection to the form.

25 Mischaracterization.

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1 A I wouldn't say that they were untrue. I

2 would just say that she printed them as journalists

3 take your words and turn them into something else.

4 Q (BY MS. MENNINGER) She got it wrong?

5 MR. EDWARDS: Object to the form.

6 Mischaracterization.
7 A In some ways, yes.
8 Q (BY MS. MENNINGER) Did she print things

9 in her articles that you did not say to her?

10 MR. EDWARDS: I object and ask that the

11 witness be given the opportunity to see the document

12 so that she can review it and answer that question

13 accurately. Otherwise she's unable to answer the

14 question. I'm not going to allow her to answer.

15 MS. MENNINGER: You know the civil rules

16 tell you not to suggest answers to your client.

17 Q (BY MS. MENNINGER) And you understand

18 your lawyer is now directing you to not all of a

19 sudden remember what your answer is. That's what

20 he's suggesting that you say. So you're not supposed

21 to listen to him suggest that to you. You're

22 supposed to tell me from your memory.

23 MR. EDWARDS: That is not what I'm --
24 Q (BY MS. MENNINGER) Did you --
25 MR. EDWARDS: That's not what I'm doing.

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1 You don't get to just talk over me and

2 tell my client when not to listen to me. All you

3 have to do to get answers is show her the document

4 you're talking about, and I'll let her answer every

5 question. I don't know why we're so scared of the

6 actual documents.
7 MS. MENNINGER: I don't know why you're

8 scared of your client's recollection, Mr. Edwards.

9 But anyway
10 MR. EDWARDS: Why would you do this to

11 her?
12 Q (BY MS. MENNINGER) Did Sharon Churcher

13 print things that you did not say?

14 MR. EDWARDS: I'm going to instruct my

15 client not to answer unless you give her what it is

16 that you're talking about that was printed. And she

17 will tell you the answer, the accurate answer to your

18 question. Just without the document to refresh her

19 recollection and see it, she's not going to answer

20 the question.
21 Q (BY MS. MENNINGER) Did Sharon Churcher

22 print things that you did not say?

23 MR. EDWARDS: Same objection. Same

24 instruction not to answer.

25 I think I've made a very clear record as

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1 to why I want my client to answer all of these

2 questions, but I want her to have the fair

3 opportunity to see this document.

4 Q (BY MS. MENNINGER) Did Sharon Churcher

5 print things that you felt were inaccurate?

6 MR. EDWARDS: Same objection. Same

7 instruction. If she sees the document, she's going

8 to answer every one of these questions.

9 Q (BY MS. MENNINGER) Did any other reporter

10 print statements that you believe are inaccurate?

11 MR. EDWARDS: Same objection. Same

12 instruction.
13 Q (BY MS. MENNINGER) Did any reporter print

14 statements about Ghislaine Maxwell that were

15 inaccurate?
16 MR. EDWARDS: Same objection. Same

17 instruction.
18 This is harassing. This is harassing a

19 sexual abuse victim. And all I'm asking is for

20 fairness, that we just let her see the document so

21 she can answer this.

22 MS. MENNINGER: Mr. Edwards, please stop

23 saying anything other than an objection, what the

24 basis is, or instructing your client not to answer.

25 MR. EDWARDS: I will do that.

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1 MS. MENNINGER: That's what the Federal

2 Rules of Civil Procedure provide.

3 MR. EDWARDS: I hear you. They also

4 provide for fairness and civility. And all I'm

5 asking, very calmly, is for her to see this.

6 MS. MENNINGER: Mr. Edwards, this is not

7 your deposition. I'm asking your client what she

8 remembers. If she doesn't want to talk about what

9 she remembers, then let her not answer. But you

10 cannot instruct her not to answer unless there's a

11 privilege.

12 What privilege --
13 MR. EDWARDS: I am instructing her not to

14 answer.
15 Q (BY MS. MENNINGER) All right. You are

16 refusing to answer questions about whether statements

17 to the press about Ghislaine Maxwell attributed to

18 you were inaccurate?

19 MR. EDWARDS: She's not refusing not to

20 answer.
21 A You are refusing to show me these
22 documents so I could answer properly. I would give

23 you an answer if you were to show me some documents.

24 Q (BY MS. MENNINGER) You can't say without

25 looking at a document whether the press attributed to

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1 you is accurate or inaccurate?

2 A Please show me the document.
3 Q You can't say from the top of your head

4 whether any inaccurate statement has been attributed

5 to you in the press?

6 A Please show me a document and I will tell

7 you.
8 Q Are you refusing to answer my questions

9 about your knowledge of whether inaccurate statements

10 have been attributed to you in the press?

11 A Are you refusing to give me the documents

12 to look at?
13 Q Are you refusing to answer the question?

14 A I am refusing to answer the question based

15 upon the fact that you are not being fair enough to

16 let me see the document in order to give you an

17 honest answer.
18 Q Ms. Giuffre
19 A Yes.
20 Q -- we are talking about press that has

21 been published on the Internet, correct?

22 A Yes.
23 Q Do you have access to the Internet?
24 A Yes.
25 Q Have you looked on the Internet and read

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1 articles that attribute statements to you about

2 Ghislaine Maxwell?
3 A Yes.
4 Q Do you know any statement that has been

5 attributed to you in a press article on the Internet

6 about Ghislaine Maxwell that is untrue?

7 MR. EDWARDS: Same objection. Same

8 instruction.
9 A Please show me a specific document.

10 Q (BY MS. MENNINGER) Do you know of any

11 such statement about Ghislaine Maxwell attributed to

12 you by the press that is inaccurate?

13 A If you could please show me a specific

14 document.
15 Q Tell me what Sharon Churcher asked you to

16 write for her.

17 A Any knowledge that I had about my time

18 with Prince Andrew.

19 Q And did you write it?
20 A Um-hum.
21 Q What did you write it in or on?
22 A Paper.
23 Q What kind of paper?
24 A Lined paper.
25 Q Was it in a book or single sheets?

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1 A Single sheets.
2 Q And did you write a long document or a

3 short document? What was it?

4 A I can't recall how long the document was,

5 but I would say it would be a few pages.

6 Q And other than asking you to write

7 whatever you remember about Prince Andrew, did she

8 give you any other directions about what you should

9 write?
10 A She was interested in two things, really.

11 How Epstein got away with so many counts of child

12 trafficking for sex and how Prince Andrew was
13 involved in it. Those were her two main inquiries.
14 Q What did she ask you to write?
15 A She asked me to write about Prince Andrew.
16 Q Did she tell you to put it in your own

17 handwriting?
18 A No, she just asked me to write down what I

19 can remember.

20 Q Did you give her everything that you

21 wrote?

22 A Did I give her the whole entire pages that

23 I wrote?
24 Q Yes.
25 A Yeah, I wrote pages for her specifically.

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1 Q In your own handwriting?

2 A In my own handwriting.

3 Q And what you wrote, was that true?

4 A Yes.

5 Q And did you get paid for those pieces of

6 paper?

7 A Not for the papers, I don't believe.

8 Q Okay. Have you gotten paid when they've

9 been reprinted?
10 A No.
11 Q Have you negotiated any deal with Radar

12 Online?

13 A No.
14 Q Have you negotiated any deal with Sharon

15 Churcher for the purpose of publishing those pieces

16 of paper?

17 A Not those pieces of paper.

18 Q When did you write those pieces of paper?
19 MR. EDWARDS: Object to the form.
20 A A week before she came out.
21 Q (BY MS. MENNINGER) And when did you give

22 them to her?

23 A When she came out.

24 Q When was that?
25 A Sometime, I believe, in early 2011.

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 Agren Blando
Case 1:15-cv-07433-LAP Court Reporting
Document & Video,
1320-30 Filed Inc. Page 27 of 27
01/03/24

1 Q What did you get paid for, if not for

2 those pieces of paper?

3 MR. EDWARDS: Object to the form.

4 A I was paid for the picture with Prince

5 Andrew with his arm around me, Ghislaine in the

6 background. And I was paid for the, I guess, the

7 print of the stories.

8 Q (BY MS. MENNINGER) Anything else?

9 A No.
10 Q You were not paid for those pieces of

11 paper?

12 A No.

13 Q All right. And how many pieces of paper

14 did you write?

15 A Like I said, I'm rounding it around three.

16 Q Three pieces of paper?
17 A That's what I -- I don't remember to be

18 exact on a number. I'm sorry. But over three pages.

19 Q And you wrote those sometime in 2011?
20 A The week that she was coming out to see

21 me.

22 Q And you gave them to her, right?

23 A I gave them to her.
24 Q Did you keep a copy of that?
25 A No.

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